ENGEL v. COMMISSIONER

Memorandum Findings of Fact and Opinion

PARKER, Judge:

By statutory notice of deficiency, dated August 29, 1989, respondent determined a deficiency in petitioners' Federal income tax for the year 1985 in the amount of $56,522. Respondent also determined additions to the tax as follows:

Sec. 6653(a)(1)    Sec. 6653(a)(2)   Sec. 6659

   $2,826.10       50% of interest   $16,956.60
                  due on deficiency
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